The Ninth Circuit has once again reversed the Tax Court in Altera v. Commissioner. The case was reheard after the untimely death of Judge Reinhardt. He was replaced on the panel by Judge Susan Graber. The change made little difference
Asbury Law Firm is a legal publisher that focuses on tax law and related litigation. Its blog covers court decisions, IRS regulations, and tax compliance issues, often analyzing significant cases such as those involving the Tax Court and the Ninth Circuit. The firm provides updates on tax filing deadlines, IRS notices, and detailed discussions of specialized tax topics like micro-captive insurance companies and syndicated conservation easements. The content is aimed at legal professionals and taxpayers interested in tax law developments and administrative law principles as they apply to tax regulation and enforcement.
Yesterday the Tax Court issued a long-anticipated opinion on a fully-litigated micro-captive insurance company. Micro-captive insurance companies have long been a popular means of self-insuring for closely-held businesses but recently have come under additional scrutiny by the IRS. This…
On April 27, 2017, the IRS issued Notice 2017-29 which extended the deadline for disclosing certain participation in syndicated conservation easements.
On December 23, 2016, the IRS announced disclosure requirements for participants in syndicated conservation easements and substantially similar transactions…